Webster Valve, Inc. South Main Street Franklin, NH 03235 

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## l l FINAL RACT ORDER March 21, 2007 ARD07-001



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A. Introduction This RACT Order is issued by the NewHampshire Department ofEnvironmental Services, Air Resources Division, t6 Webster Valve, Inc., pursuant to RSA 125-C. B. Parties 1. TheNew Hampshire Department ofEnvironmental Services, Air Resources Division (DES), is a duly constituted administrative agency ofthe State ofNewHampshire having its principal offices at 29 Hazen Drive, Concord, NH 03302, telephone number (603) 271-1370. 2. Webster Valve, Inc. (Webster Valve) is a New Hampshire corporation doing business at the mailing address ofSouth Main Street, Franklin, NH 03235, telephone number (603) 934-1327. C. Statements ofFact and Law 1. Webster Valve owns and operates a facility located on SouthMain Street in Franklin, NH primarily engaged in the manufacturing ofvalves, regulators and backflow prevention devices for plumbing and heating and water quality applications. Operations at the facility include coating ofthe metal parts in one ofsix spray booths. 2. Effective December 31, 2002, DES re-adopted the NewHampshire Code ofAdministrative Rules**Env~A** 1204, Stationary Sources ofVolatile Organic Compounds (VOCs) with amendments. This part defines the sources that are subject to Reasonably Available Control Technology (RACT) requirements and specifies the RACT requirements. 3. Webster Valve is subject to Env-A 1204.15,Applicability Criteria and Compliance Standards for Coating of Miscellaneous Metal Parts andProducts, because the theoretical potential to emit (TPE) exceeds l0 tons ofnon-exempt VOCs during any consecutive 12-monthperiod. 4. Webster Valve submitted a VOC RACT compliance plan on October 26, 1994 stating that a regenerative thermal oxidizer (RTO) along with emissions averaging would be used to comply with the requirements ofEnv-A 1204.15. 5. On April25, 2001, Webster Valve submitted a modified VOC RACT compliance plan, proposing to discontinue the use ofthe RTO and use Discrete Emission Reductions (DERs) to

. comply with the requirements ofEnv-A 1204.15. 6. OnMay 21, 2001, Webster Valve acquired 120 DERs (60 ozone season DERs and 60 nonozone season DERs) from Public Service ofNewHampshire, as generated in accordance with the federally enforceable RACT Order No. ARD-98-001, approved as part ofthe State ImplementationPlaninthe Federal Register Volume 65, page 68078 dated November 14,2000. 7. OnMay 24, 2001, DES approved Webster Valve's modified VOC RACT compliance plan.RACTOrderNo. ARD07-001 Webster Valve, Inc. March 21, 2007 Page 2 of6 8. State Permit to Operate, FP-S-0167 was issued on October 24,2001 to Webster Valve. Condition V.B ofthe permit allows Webster Valve to use DERs to complywithVOC RACT requirements. 9. On June 23,2006, Webster Valve submitted an applicationto renew State Permit to Operate, FP-S-0167. This application also serves as the applicationto obtain a VOC RACT Order for the use ofDERs for compliance. 

### D. Order Based onthe statements offact and law, DES hereby orders Webster Valve, effective upon issuance ofthis Order, to comply with the following requirements as RACT: 1. Coating ofMiscellaneous Metal Parts and Products under Env-A 1204.15:

a. For those processes applying a protective, decorative or functional coating onto metal parts and products, Webster Valve shall comply withthe following emission limits for each coating used. All limits are inunits ofpounds ofVOC per gallon ofcoating, as applied, excluding water and exempt compounds. Emissions in excess ofthese limits shall be offset bythe use ofDERs in accordance withPartE below: (i) For a coating that is a clear or transparent top coat, as defined in Env-A 1204.03, 4.3 lbs VOC/gal coating; (ii) For a coating that is used in extreme environmental conditions, as defmed in Env-A 1204.15, 3.5 lbs VOC/gal coating; (iii) For a coating that is air dried, as defined inEnv-A 1204.15, 3.5 lbs VOC/gal coating; and (iv) For all other coatings, 3.0 lbs VOC/gal coating. b. Ifmore than one emission limit inD.l.aapplies to a specific coating, thenthe least stringent emission limitation shall be applied. 2. Calculation ofEmission Standard On a Solids Basis For determining the amountofDERs to be used in accordance with PartEbelow, the emission rate limit shallbe determined on a solids basis, as specified below: (i) "S"means the VOC emission standard interms ofpounds VOC per gallon ofcoating solids; (ii) "Ec" means the VOC emission limit as stated in Part D.l, above; and (iii) "dA" means the actual mass density ofthe VOC inthe applied surface coating formulation in terms oflb VOC/gal VOC; and (iv) S shall be equal to Ec divided by the difference between one and the quotient ofEc and dA, as inthe following equation:RACTOrderNo. ARDOl-001 Webster Valve, Inc. 3. Calculation ofAllowable VOC Emissions per Coating The allowable VOC emissions shall be calculated for each coating as follows: March 21, 2007 Page 3 of6

(i) "Eatmeans the allowable VOC emission rate ofa given coating in units oflb/month or kg/month; (i) "S" means the VOC emission standard in terms oflb VOC/gal or kg VOC/1 ofcoating solids, as calculated inPart D.2, above; (ii) "W" means the weight ofcoating or dilution solvent used in the coating line on a given day in units oflb/month or kg/month; (iii) "D" means the density ofthe coating or dilution solvent in units oflb/gal coating, or kg/! coating as determined from Method 24 or 24A analysis; (iv) "VS" means the volume fraction solids content ofthe coating, inunits ofgal solids/gal coating or I solids/1 coating as determined by calculation using the formulation; and (v)" Eat" shall be equal to the product ofS, VS and W divided by D for each coating or dilution solvent used, as in the following equation: Eat= S*VS*(W/D) 4. Calculation ofActual VOC Emissions per Coating The VOC emissions shall be calculated for each coating as follows: (i) "Eac" means the actual VOC emission rate ofa given coating in units oflb/month; (ii) "W" means the weight ofcoating or dilution solvent used inthe coating line on a given dayinunits oflb/month; (iii) "WV"means the weight fraction ofVOC content ofthe coating, inunits oflb VOC/lb coating as determined by calculation using the formulation; and (iv) "Eac" shall be equal to the product ofW and WV, as in the following equation: Eac=·W*WV 5. Calculation ofExcess Emissions per Coating The amount ofVOC emissions emitted in excess ofthe applicable limit for each coating shall be equal to the difference between the actual VOC emission rate (Eac) from the allowable VOC emission rate CEat). Ifthe calculated excess emissionrate is a negative number, no additional calculation is required. Ifthe calculated excess emissionrate is a positive number, the excess emissionrate shall be divided by an environmental benefit factor of0.9. 6. Demonstration ofCompliance Webster Valve shall either test all coatings using the Methods described below, orretain sufficientrecords for prima facie evidence in support ofdemonstrating compliance withthe VOC RACT limit.

a. Method 24, 40 CFR Part 60, Appendix A at 1-hour bake time, or an alternative test method approved bythe Director and EPA; orRACTOrderNo. ARD07-00J Webster Valve, Inc. March 21, 2007 Page 4 Of6 b. Method 24A, 40 CFRPart 60, Appendix A, or an alternative test method approved by the Director and EPA. Primafacie evidence shall include all ofthe information required by the VOC data sheet found on eitherpage II-2 or ill-2, as applicable, ofEPA document EPA-450/3-84-019, Procedures for CertifYing Quantity of Volatile Organic Compounds EmittedbyPaint, Ink, and Other Coatings, dated 1984. Ifthere is a discrepancy between the formulation data and the results ofthe Method 24 or 24A analysis, compliance shall be based onthe results from the Method 24 or 24A analysis. 7. Recordkeeping Requirements WebsterValve shall maintain the following records in order to demonstrate compliance with this order. Eachrecord shall be kept for a period ofat least five years.

a. Records oftests conducted pursuant to Part D.5, above. b. Records ofprimafacie evidence gathered pursuant to Part D.5, above.

c. Records required to be maintained pursuant to Env-A 904, VOC Emission Statements RecordkeepingRequirements, except that actual VOC emissions shall be recorded on a monthly basis instead ofan armual basis. 8. Reporting Requirements Webster Valve shall submit the following reports:

a. Emissionreports in accordance withEnv-A 908, VOC Emission Statements Reporting Requirements; and b. Discrete Emissions Reductions reports in accordance with Part E. 

### E. Emissions Reductions Credits 1. Webster Valve shall be allowed to use discrete emissions reductions (DERs) for the purpose of satisfying the requirements ofthis Order by acquiring DERs from Public Service ofNew Hampshire, as generated in accordance withthe federally enforceable RACT OrderNo. ARD-98-001, approved as part ofthe State ImplementationPlaninthe Federal Register Volume 65, page number 68078 dated November 14, 2000, or other emission trading credits approved for use inNewHampshire. 2. DERs certified for reductions ofnitrogen oxides (NOx) may be substituted for VOC reductions in a ratio ofI :I, or an alternative ratio approved byDES and EPA. 3. Annually byNovember 30, Webster Valve shall submit a report to DES onthe projected use of credits for the upcoming year. This report shall meet the requirements ofEnv-A 3104.08, Notice of intent to Use DERs, including the following information:

a. The name and location ofthe user; b. A copy ofthe Notice and Certification ofGeneration submitted by the generator source to the State (forpaperwork reduction purposes, a certified statement that the notice is on file with DES will suffice);

c. Theprotocol used to document the amount ofDERs needed to demonstrate compliance; andRACTOrder No. ARDOl-001 Webster Valve, Inc. March 21, 2007 Page 5 of6 d. Information that will allow DES to determine that Webster Valve is in compliance with Env-A 1400, Regulated ToxicAirPollutants. 4. Annuallyby April IS, Webster Valve shall submit a report to DES on the balance ofcredits for the previous calendar year. This report shall meet the requirements ofEnv-A 3104.09, Notice andCertification ofUse, including the following information:

a. The name and location ofthe owner or operator ofthe user source; b. The cost ofthe DERs;

c. The amount ofDERs used and the associated serial numbers assigned bythe DES; d. A calculation ofthe amount ofDERs required to demonstrate compliance with the emission limits stated in Part D, above. DERs shall be calculated on an annual basis by summing the monthly excess emissions as calculated in Part D.S, above.

e. A statementthat due diligence was made to verifY that the DERs were notpreviously used, and not generated as a result ofactions prohibited under the regulations or other provisions oflaw; f. A statement that the DERs were not used in a manner prohibited undertheregulation or other provisions oflaw; and g. A copy ofthe relevant Notice and Certification ofGeneration (for paperworkreduction purposes, a certified statement that the notice is onfile with DES will suffice). h. TheNotice ofCertification ofUse shall contain a certification by a responsible official of truth, accuracy and completeness and shall state that: (i) Based on information and beliefformed after reasonable inquiry, the statements and information in the document are true, accurate and complete; and (ii) The user source is in compliance with all National Ambient Air Quality Standards, except ground level ozone, and all Ambient Air Limits for Regulated Toxic Air Pollutants. Please address any correspondence and communication inreference to this Order to the following: Ms. BarbaraDorfsclunidt NHDES, AirResources Division Stationary Source Management Bureau 29 HazenDrive P.O. Box 95 Concord, NH 03302-0095 (603) 271-6796RACTOrderNo. ARD07-00J Webster Valve, Inc. March 21, 2007 Page 6 of6 Please address any correspondence and communication inreference to the ERCs orDERs to the following: Mr. Joe Fontaine NHDES, Air Resources Division 29 HazenDrive P.O. Box 95 Concord, NH 03302-0095 (603) 271-6794

cc: Timothy Drew, PIP Office Ann Arnold, USEPA Town ofFranklin Ken Boivin, GZA GeoEnvironmental Robert R. Scott Director Air Resources Division